Brazilian DPA announces a Public Hearing on the definition of High-Risk Personal Data Processing

Recently, the Brazilian National Data Protection Authority (“ANPD” or “Brazilian DPA”) announced a Public Hearing to receive the society's contributions and support the draft of a Guideline on High-Risk Personal Data Processing ("Guideline"), in compliance with the Brazilian General Data Protection Law ("LGPD") and the Regulation for Small Processing Agents ("Regulation"), established by Resolution CD/ANPD no. 02/2022.

The Regulation, analyzed in this newsletter, establishes that a data processing will be considered as high-risk if it meets at least one generic and one specific criterion provided in its text.

However, the definition of high risk and its particularities presents a high level of complexity, sparking significant debate and generating uncertainty for data processing agents. Thus, the ANPD chose to develop the Guideline, aiming to provide greater clarity regarding the assessment of data processing and its classification as high-risk processing, as well as the interpretation of the general and specific criteria outlined in the Regulation.

Contributions must be submitted electronically by May 16, 2024, exclusively through the Participa Mais Brasil platform, available at the following link:

Our team is available for further clarification, as well as to advise on the procedures for complying with the regulatory obligations of the LGPD before the ANPD.

Gustavo Flausino Coelho –

Fernando Naegele –

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